Control of Suspect/Counterfeit Items

24590-RAPR-F00001 Rev 15 (Revised 7/23/2019) Page 1 of 27 Ref: 24590-WTP-GPP-RAPR-PR-1001

Hanford Tank Waste Treatment and Immobilization Plant

Document Owner

BNI-WTP Applicability Project Phase Organization Use Level of Use

Project Wide All Cross-Functional Information

Care, Custody, and Control N/A

Procedure

24590-WTP-GPP-RAQA-QA-0003 Revision 5

Control of Suspect/Counterfeit Items

Effective Date: 06/25/2020

Requirement Area: Quality Assurance

Position Print Name Signature Date

RA SME Dan Hart

RAM Rajwant Jolly

BNI-WTP Quality Mike Fortier

06/24/2020

24-JUN-2020

06/24/2020

Issued byRPP-WTP PDC

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Electronic documents, once printed, are UNCONTROLLED and may become outdated. Refer to the electronic documents in InfoWorks for current revision.

Control of Suspect/Counterfeit Items 24590-WTP-GPP-RAQA-QA-0003, Rev 5 Level of Use: Information


Contents

1.0 PURPOSE ............................................................................................................ 5

2.0 SCOPE ................................................................................................................. 5

3.0 ROLES AND RESPONSIBILITIES ...................................................................... 5 3.1 BNI-WTP MANAGER OF QUALITY .......................................................... 5 3.2 BNI-WTP AND WTCC ORGANIZATION MANAGERS .............................. 5 3.3 MANAGER OF ENGINEERING AND DESIGN AUTHORITY .................... 5 3.4 ASSET MANAGEMENT ............................................................................ 5 3.5 MANAGER OF PROCUREMENT AND SUBCONTRACTS ....................... 6 3.6 SUBCONTRACT/PROCUREMENT INTERFACE ..................................... 6 3.7 CONTRUCTION MANAGER ..................................................................... 6 3.8 WTCC QUALITY MANAGER ..................................................................... 6 3.9 BNI-WTP/WTCC EVALUATION TEAM ..................................................... 6 3.10 SUSPECT/COUNTERFEIT ITEMS COORDINATOR ................................ 6 3.11 SUPPLIER QUALITY ................................................................................. 7 3.12 S/CI IDENTIFIER (BNI-WTP/WTCC EMPLOYEE/ONSITE

SUBCONTRACTOR/SUPPLIER) .............................................................. 7

4.0 PRECAUTIONS AND LIMITATIONS ................................................................... 7

5.0 PREREQUISITES ................................................................................................ 7

6.0 PROCEDURE ....................................................................................................... 8 6.1 GENERAL .................................................................................................. 8 6.2 IDENTIFICATION OF QUESTIONABLE ITEMS BY WTP EMPLOYEE .. 12 6.3 IDENTIFICATION OF QUESTIONABLE ITEMS BY

SUBCONTRACTOR/SUPPLIER ............................................................. 16 6.4 S/CI RETENTION PROCESS .................................................................. 19 6.5 EXTERNAL S/CI NOTIFICATIONS AND REVIEW PROCESS ............... 19 6.6 EXTERNAL DI NOTIFICATIONS AND REVIEW PROCESS ................... 19

7.0 ACCEPTANCE CRITERIA ................................................................................. 20

8.0 TRAINING .......................................................................................................... 20

9.0 RECORDS.......................................................................................................... 20

10.0 REFERENCES ................................................................................................... 20 10.1 INTERFACING REFERENCES ............................................................... 20 10.2 DEVELOPMENTAL REFERENCES ........................................................ 21 10.3 FORM REFERENCES ............................................................................. 21




Attachments ATTACHMENT 1 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS ................ 22 ATTACHMENT 2 S/CI INDICATORS ........................................................................ 23 ATTACHMENT 3 WTP EMPLOYEE FLOWCHART ................................................. 26 ATTACHMENT 4 SUBCONTRACTOR/SUPPLIER FLOWCHART .......................... 27




REVISION – SUMMARY Justification: Section/Step Revision Type* Description

Throughout Major This revision incorporates NCR program ownership updated to WTCC Quality Manager. Updated procedure references to 24590-WTP-GPP-RAQS-NC-0001, and 24590-WTP-GPP-RAQS-NC-0002. Updated to reflect current project links. Updated formatting.

1.0 Added a statement to describe process for external notifications of S/CI and defective items

3.7 Changed role from Manager of Construction to WTCC Quality Manager

6.1.1 Changed CAMP to Contractor Assurance.

6.1.5 Moved Trend Analysis to S/CI Coordinator.

6.2.5, 6.3.7 Describe dispositioning S/CI

6.5 New section to describe process for responding to external S/CI notifications

6.6 New section to describe process for responding to external DI notifications

Attachment 3, Attachment 4

Updated to reflect dispositioning of S/CI

Attachment 5 Removed requirement references

* Major, Minor, or Expedited

REQUIRED REVIEWERS

☒ Asset Management (WTP CPMS Doc Review)

☒ BNI- WTP Quality (WTP Quality Document Review Mailbox)

☒ Document Administration – Procedures (WTP PI Document Review)

☒ Safety & Health (WTCC Safety and Health)




1.0 PURPOSE

This procedure describes the requirements and administrative controls for identifying, documenting, analyzing, dispositioning, reporting, controlling, and disposing of suspect/counterfeit items (S/CIs). This procedure also establishes the requirements for notifying the Office of Inspector General (OIG) of S/CIs. The objective is to prevent the inadvertent requisition, procurement, acceptance, and installation of S/CIs. This procedure also describes the process for screening, distributing, and reviewing external notifications of S/CIs and defective items (DIs) for project impact.

2.0 SCOPE

This procedure applies to safety and non-safety systems, structures, and components; critical load path of hoisting and rigging equipment; industrial safety items; and any items (including non-permanent) within the WTP where the introduction of the S/CIs would have the potential for creating unsafe conditions.

3.0 ROLES AND RESPONSIBILITIES

3.1 BNI-WTP MANAGER OF QUALITY

Has overall responsibility for implementation of S/CI Program

3.2 BNI-WTP AND WTCC ORGANIZATION MANAGERS

Ensures work processes for which they are responsible have adequate controls to prevent introduction and use of S/CIs

Ensures subcontractors and suppliers are advised of unacceptability of S/CIs

Ensures work processes for purchased items provide for examination of S/CI indicators

3.3 MANAGER OF ENGINEERING AND DESIGN AUTHORITY

Ensures participation in the inspection and testing of items that exhibit S/CI indicators as well as confirmed S/CIs, both pre- and post-installed

Specifies testing for procured or installed S/CIs, as necessary, using approved Engineering test methods

Ensures NCRs have suitable instructions for disposition of S/CIs

3.4 ASSET MANAGEMENT

Dispositions S/CIs as appropriate




3.5 MANAGER OF PROCUREMENT AND SUBCONTRACTS

Ensures procurement process controls contain provisions specific to prohibited procurement of S/CIs

Ensures S/CI requirements are flowed down to subcontractors/suppliers as well as sub-tier suppliers as indicated in contractual agreements

Ensure work processes are implemented for acceptance of only those items that comply with procurement specifications, consensus standards, and commonly accepted industry practices as well as being free from S/CI indications

Disseminates applicable information to affected subcontractors and suppliers to the extent authorized

Ensures work processes are implemented for surveillances of material management storage areas and inspections of inventory to identify, control, and assist in dispositions of S/CIs

3.6 SUBCONTRACT/PROCUREMENT INTERFACE

Notifies S/CI Coordinator when a subcontractor/supplier identifies potential S/CI

Notifies subcontractor/supplier of S/CI determination

Initiates nonconformance report (NCR) if an S/CI is impounded

3.7 CONTRUCTION MANAGER

Provides controls for processes that could introduce S/CIs

3.8 WTCC QUALITY MANAGER

Provides controls for processes that could introduce S/CIs

Ensures NCR process provides adequate controls for identified S/CIs

WTCC POC for S/CI information

3.9 BNI-WTP/WTCC EVALUATION TEAM

Investigates potential S/CIs for validity

3.10 SUSPECT/COUNTERFEIT ITEMS COORDINATOR

Develops, maintains, and provides oversight of the S/CI Program

Leads evaluation team to investigate questionable items

Serves as the Point of Contact (POC) for OIG communications

Develops and maintains the S/CI log

Notifies project management of S/CIs and defective items (DIs) that may affect the WTP project




Tracks questionable item notifications and results for trending and metrics reporting

Conducts program effectiveness reviews

Conducts NCR validation for S/CI specific NCRs

3.11 SUPPLIER QUALITY

Identifies items that exhibit S/CI indicators as questionable during the receiving process and documents on Unsatisfactory, Over, Short, and/or Damaged (UOS&D) Report

Notifies the S/CI Coordinator and initiate an NCR for items that exhibit S/CI indicators

3.12 S/CI IDENTIFIER (BNI-WTP/WTCC EMPLOYEE/ONSITE SUBCONTRACTOR/SUPPLIER)

Identifies questionable items that exhibit S/CI indicators

Secures questionable items to prevent their use

Contacts appropriate management and the S/CI Coordinator immediately upon discovery of a questionable item which exhibits S/CI indicators

Initiates an NCR when discovering an item that exhibits indications of being S/CI

4.0 PRECAUTIONS AND LIMITATIONS

N/A

5.0 PREREQUISITES

N/A




6.0 PROCEDURE

NOTE:

The steps in this procedure are intended to be used as needed, depending on the procedure attribute of interest, and not in a prescribed sequence except as noted.

6.1 GENERAL

6.1.1 The managers who are responsible for the respective work processes PERFORM the following steps:

NOTE:

The following work process controls are the responsibility of the BNI-WTP Manager of Quality, WTCC Quality Manager, Construction Manager, Manager of Procurement and Subcontracts, Manager of Engineering and Design Authority, Manager of Field Quality Control, Safety & Health Manager, Plant Engineering and Maintenance Manager, and Deputy General Manager

a. ENSURE the following work processes have adequate controls to prevent the introduction and use of S/CIs as applicable:

Engineering

Design

Procurement

Testing

Inspection

Maintenance (including replacement and modification)

Evaluation

Disposition

Lessons Learned

b. ENSURE appropriate codes, standards, and quality requirements are included in the procurement and subcontract documents to ensure that suppliers are advised of the unacceptability of S/CIs.

c. ENSURE procurement documents for both material and services contain the following information:

Requirements that prohibit the delivery of S/CIs and prohibit subcontractors from introducing S/CIs to the WTP

Requirements that specify items be new and not reconditioned, used, or repaired unless otherwise specified in the procurement document.




d. ENSURE purchased items are examined for questionable S/CI part indicators, in accordance with this procedure.

e. EVALUATE S/CI-related NCRs for potential trends as part of the preparation of Contractor Assurance quarterly trending. (24590-WTP-GPP-RACA-TM-0001, Trend Analysis and Reporting provides details)

f. ISSUE Lessons Learned reports, as appropriate, and REVIEW for use in improving the prevention and identification of S/CIs. (24590-WTP-GPP-RACA-LL-0001, WTP Lessons Learned provides details)

g. DO NOT DESTROY, ALTER, or DISPOSE of identified S/CIs or documentation without reporting to DOE and obtaining the authorization of the OIG.

6.1.2 The Manager of Procurement and Subcontracts PERFORMS the following steps:

a. ENSURE work processes are implemented such that technical and Quality Assurance (QA) requirements to prevent the introduction of S/CIs are identified in requisition packages and passed on to manufacturers, suppliers, and subcontractors.

NOTE:

Current information on S/CI detection and a list of S/CI and DI notifications can be found on the WTP project intranet home page under Safety and Quality.

b. ENSURE work processes are implemented, to the extent authorized for external distribution, such that project suppliers and subcontractors are made aware that project-applicable S/CI and DI notifications obtained from the following sources can be accessed via a password protected external website (http://www.hanfordvitplant.com/suspectcounterfeit-items), along with the appropriate guidance on the prevention of providing S/CIs to the WTP:

DOE Office of Health, Safety, and Security (HSS) S/CI and DI Website

Government-Industry Data Exchange Program (GIDEP)

Institute of Nuclear Power Operations (INPO)

Occurrence Reporting and Processing System (ORPS)

c. ENSURE procurement process controls include provisions for preventing the procurement of S/CIs in accordance with this procedure.

d. ENSURE proformas contain requirements to prevent introduction of S/CIs to WTP.




e. ENSURE work processes are implemented such that acceptance is made of only those items that comply with procurement specifications, consensus standards, and commonly accepted industry practices.

f. ENSURE work processes are implemented such that inventory is inspected and surveillances of material management storage areas are performed in accordance with project procedures to identify, control, and disposition potential S/CIs.

6.1.3 The Construction Manager PERFORMS the following step:

a. ENSURE controls are provided for the following processes for S/CIs installed that create potential hazards:

Identification

Inspection

Documentation

Evaluation

Segregation when practical

Notification of relevant organizations

Disposition

6.1.4 The WTCC Quality Manager PERFORMS the following step:

a. ENSURE controls are provided for the following processes for S/CIs installed that create potential hazards:

Identification

Inspection

Documentation

Evaluation

Segregation when practical

Notification of relevant organizations

Disposition

b. ENSURE the NCR process provides controls that ensure S/CIs identified during routine maintenance and/or inspection are reported, evaluated, and dispositioned to prevent future use in safety applications.

c. ENSURE information regarding S/CIs is communicated with WTCC Management.




6.1.5 The Manager of Engineering and Design Authority PERFORMS the following steps:

a. PARTICIPATE in the inspection and testing of identified potential S/CIs and confirmed S/CIs, both pre- and post-installation.

b. ENSURE the technical and Quality Assurance (QA) requirements are identified in requisition packages.

c. ENSURE NCRs on contaminated (e.g. radiological, chemical) S/CIs take into consideration the facility/program-specific waste management procedures when determining the disposition of the S/CI.

NOTE:

Current information on S/CI detection and a list of S/CI and DI notifications can be found on the WTP project intranet home page.

6.1.6 The S/CI Coordinator PERFORMS the following steps:

a. USE the online listing found on the WTP project intranet home page to collect, maintain, and disseminate S/CI and DI information pertinent to the WTP work scope.

b. MAINTAIN the S/CI and DI list up-to-date and accurate using available sources including:

DOE HSS S/CI and DI Website

Government-Industry Data Exchange Program (GIDEP)

Institute of Nuclear Power Operations (INPO)

Occurrence Reporting and Processing System (ORPS)

c. ENSURE S/CIs identified and associated documentation is retained in case it is needed for criminal investigation or litigation.

d. PERFORM trend analysis of reported S/CIs annually, in accordance with 24590-WTP-GPP-RACA-TM-0001, Performance Measures and Trending.

6.1.7 Manager of Engineering and Design Authority ENSURES support is provided for the following steps:

a. PERFORM an Engineering evaluation, using approved test methods (i.e., in accordance with applicable codes/standards), to determine procured or installed S/CIs do not pose a potential safety hazard and meet design requirements. Also consider the potential risks to the public and workers, cost/benefit impact, and schedule for replacement, if required.

b. PROVIDE a disposition to perform one of the following:




To leave the S/CI installed and clearly identified to the workforce with appropriate design change documentation, as required

To remove and replace the S/CI

To provide for an alternate outcome

c. PARTICIPATE in replacing, maintaining, or modifying equipment

6.2 IDENTIFICATION OF QUESTIONABLE ITEMS BY WTP EMPLOYEE

NOTE:

It is the responsibility of all project employees to report questionable items that exhibit S/CI indicators to their manager/supervisor and the S/CI Coordinator. Typical S/CI indicators can be found on Attachment 2. Records from Kobe Steel Ltd, Kobe Steel USA, Kobelco, or other implicated affiliates, are considered an S/CI Indicator, based on their admittance of record falsification.

An additional listing of indicators of S/CIs can be found in DOE S/CI Guide 414.1-3 Appendix 4 which can be found on the S/CI homepage, which is located on the WTP Project home page under Safety and Quality.

The WTP Employee process flowchart can be found on Attachment 3. For better viewing, the zoom feature in the electronic version may be used.

6.2.1 Supplier Quality PERFORM the following steps:

a. IF during the receiving process an item exhibits S/CI indicator(s) (examples in Attachment 2), THEN IDENTIFY the item as questionable.

1. NOTIFY supervision and COMPLETE receiving or inspection process in accordance with 24590-WTP-GPP-RAPS-SQ-1044, Field Material Receiving, and/or 24590-WTP-GPP-RAPS-SQ-1041, Receiving Inspections, as appropriate.

2. NOTIFY the S/CI Coordinator.

b. WHEN receiving or inspection process is complete, THEN INITIATE an NCR in accordance with 24590-WTP-GPP- RAQS-NC-0002, Nonconformance Reporting and Control and GO TO Step 6.2.3.

6.2.2 The WTP employee PERFORMS the following steps:

a. IF some item exhibits S/CI indicators, (examples in Attachment 2), THEN PERFORM the following

1. IDENTIFY the item as questionable,

2. NOTIFY the S/CI Coordinator, and




3. INITIATE an NCR in accordance with the governing procedure noted below:

a) For items controlled by Material Management, Construction, or Startup, work in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.

b) For items handed over to Plant Management, work in accordance with 24590-WTP-GPP-RAQS-NC-0001, Operating Nonconformance Reporting and Control.


a. VERIFY the item that exhibits indications of being a S/CI is secured from being used.

b. VALIDATE the NCR when appropriate.

c. INITIATE S/CI log entry and provide communication to WTCC POC.

d. INVESTIGATE item in question and gather information (e.g., photographs, procurement documents).

e. IF the investigation of the questionable item becomes complex in nature, THEN ASSEMBLE a team of appropriate personnel (i.e., Technical Specialists) to evaluate the item.

6.2.4 The BNI WTP/WTCC Evaluation Team PERFORMS the following steps:

a. EVALUATE questionable item regarding S/CI validity.

b. NOTIFY S/CI Coordinator with results.

6.2.5 The S/CI Coordinator, PERFORMS the following steps:

a. SERVE as the S/CI Point of Contact with the Office of Health, Safety, and Security,

b. DETERMINE whether the item is S/CI using input from the Evaluation Team.

c. DOCUMENT the determination on the NCR, or with a surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.

d. IF the item is determined to be a S/CI, THEN PERFORM the following:

1. NOTIFY the following within 3 days of the determination via email using a CCN:




DOE

Office of Environmental, Safety, and Health

OIG

2. NOTIFY Occurrence Reporting.

3. UPDATE S/CI log with determination.

NOTE:

The OIG typically responds within 10 days. The response identifies the OIG’s intent regarding a course of action.

4. IF OIG response is not received within 10 working days, THEN CONTACT OIG and OBTAIN a timeframe in which their response will be provided.

5. UPDATE S/CI log with OIG response.

6. WHEN response is received from OIG, THEN NOTIFY affected management, utilizing the project organizational chart, of path forward regarding OIG disposition.

NOTE:

Items determined as S/CI are dispositioned in one or more of the following three methods. Quantities may be split between the various methods.

• Ship to OIG

• Make available to S/CI training for use as a training aid

• Disposal by Asset Management

Material Management processes shipments of government property in accordance with 24590-WTP-GPP-RAPS-MM-1103, Field Material Withdrawal and Shipping.

7. UPDATE the NCR disposition to reflect OIG response.

a) IF the OIG requests the items, THEN SELECT “Reject” disposition

1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the OIG.

b) IF items are requested to be retained for S/CI training, THEN SELECT “Reject” disposition




1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the S/CI coordinator.

2) RETAIN S/CI item for training purposes if not requested by OIG, in accordance with section 6.4.

c) IF items are to be disposed of as excess, THEN SELECT “Reject” disposition

1) SUBMIT DECEX form 24590-GPA-F00006 in accordance with 24590-WTP-GPP-RAPS-GP-1028.

e. IF the item is determined not to be a S/CI, THEN PERFORM the following:

1. NOTIFY S/CI Identifier that the item has been determined to not be S/CI.

2. UPDATE the S/CI log.

3. CONTINUE the NCR process.

6.2.6 Asset Management PERFORMS the following steps:

a. IF the NCR requires disposal of the item, THEN DISPOSE the S/CI item. (24590-WTP-GPP-RAPS-GP-1028, Government Property – Scrap/Salvage provides details).




6.3 IDENTIFICATION OF QUESTIONABLE ITEMS BY SUBCONTRACTOR/SUPPLIER

NOTE:

It is the responsibility of all subcontractor/suppliers that are located directly on the WTP site to report questionable items that have been delivered and are located at the WTP project that exhibit S/CI indicators to their manager/supervisor and the S/CI Coordinator. Typical S/CI indicators can be found on Attachment 2. Records from Kobe Steel Ltd, Kobe Steel USA, Kobelco, or other implicated affiliates, are considered an S/CI Indicator, based on their admittance of record falsification.

An additional listing of indicators of S/CIs can be found in DOE S/CI Guide 414.1-3 Appendix 4 which can be found on the S/CI homepage, which is located on the WTP Project home page under Safety and Quality.

The subcontractor/supplier process flowchart can be found on Attachment 4. For better viewing, the zoom feature in the electronic version may be used.

6.3.1 The WTP on site Subcontractor/Supplier (including sub-tier) PERFORMS the following steps:

a. IF an item exhibits S/CI indicator(s), (examples in Attachment 2) THEN IDENTIFY the item as questionable and SECURE item from use by segregation and/or tagging.

b. NOTIFY WTP Subcontract/Procurement interface and PROVIDE information regarding item.

6.3.2 The Subcontract/Procurement interface PERFORMS the following step:

a. NOTIFY the S/CI Coordinator regarding questionable items discovered by the subcontractor/supplier.


a. INITIATE S/CI log entry and provide communication to WTCC POC.

b. INVESTIGATE item in question and gather information (photographs, procurement documents, etc.).

c. IF the investigation of the questionable item becomes complex in nature, THEN ASSEMBLE a team of appropriate personnel (i.e., Technical Specialists) to evaluate the item.

6.3.4 The Evaluation Team PERFORMS the following steps:

a. EVALUATE questionable item regarding S/CI validity.




b. NOTIFY S/CI Coordinator with results.


a. DETERMINE whether the item is S/CI using input from the evaluation team.

b. IF the item is determined to be a S/CI, THEN PERFORM the following:

1. DOCUMENT the determination with a Surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.

2. NOTIFY Subcontractor/Procurement interface to impound WTP owned item and control the S/CI in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.

c. IF item is not S/CI, THEN PERFORM the following:

1. NOTIFY S/CI Identifier (Subcontractor/Procurement interface) that item has been determined to not be S/CI.

6.3.6 The Subcontract/Procurement interface PERFORMS the following step:

a. WHEN notified by the S/CI Coordinator that an item has been determined to be S/CI, THEN IMPOUND and CONTROL the WTP owned S/CI in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.

b. IF an NCR has not yet been initiated, THEN INITIATE an NCR in accordance with 24590-WTP-GPP-RAQS-NC-0002, Nonconformance Reporting and Control.


a. WHEN an item has been determined to be S/CI, THEN PERFORM the following:

1. VALIDATE the NCR that was initiated to document the S/CI.

2. NOTIFY the following within 3 days of the determination via email using a CCN:

DOE

Office of Environmental, Safety, and Health

OIG




3. NOTIFY Occurrence Reporting.

4. UPDATE S/CI log with determination.

NOTE:

The OIG typically responds within 10 days. The response identifies the OIG’s intent regarding a course of action.

5. IF OIG response is not received within 10 working days, THEN CONTACT OIG and OBTAIN a timeframe in which their response will be provided.

6. UPDATE S/CI log with OIG response.

7. WHEN response is received from OIG, THEN NOTIFY affected management, utilizing the project organizational chart, of path forward regarding OIG disposition.

8. UPDATE the NCR disposition to reflect OIG response.

a) IF the OIG requests the items, THEN SELECT “Reject” disposition

1) SUBMIT Shipping Request Form 24590-GCB F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the OIG.

b) IF items are requested to be retained for S/CI training, THEN SELECT “Reject” disposition

1) SUBMIT Shipping Request Form 24590-GCB-F00006 in accordance with 24590-WTP-RAPS-MM-1103, Field Material Withdrawal and Shipping and identify the Shipping Notice Type as “Return No Replacement” and indicate shipment to the S/CI Coordinator.

2) RETAIN S/CI item for training purposes if not requested by OIG, in accordance with section 6.4.

c) IF items are to be disposed of as excess, THEN SELECT “Reject” disposition

1) SUBMIT DECEX form 24590-GPA-F00006 in accordance with 24590-WTP-GPP-RAPS-GP-1028.

6.3.8 Asset Management PERFORMS the following steps:




a. IF the NCR requires disposal of the item, THEN DISPOSE the S/CI item. (24590-WTP-GPP-RAPS-GP-1028, Government Property – Scrap/Salvage provides details).

6.4 S/CI RETENTION PROCESS

6.4.1 S/CI Coordinator PERFORMS the following steps for retained items:

a. WHEN S/CI is turned over to the S/CI Program for retention, THEN VERIFY the item is rendered useless.

b. ENSURE the item is:

Tagged with identification number

Recorded in S/CI Retention Log

Secured in S/CI Storage

6.5 EXTERNAL S/CI NOTIFICATIONS AND REVIEW PROCESS

6.5.1 S/CI Coordinator PERFORMS the following steps:

a. SCREEN S/CI notifications that are communicated through various sources to determine site-specific relevance, risks, and vulnerabilities.

NOTE:

Safety concerns are discussed with Safety and Health Management to determine if immediate/compensatory action should be initiated.

b. For S/CIs applicable to the site, INITIATE S/CI log entry.

c. INVESTIGATE (which includes distribution to applicable individuals) to determine if the item exists at the WTP, through interviews, word search of project documents, etc. If the item exists at WTP, go to section 6.2.2.

d. DOCUMENT the determination with a Surveillance report in accordance with 24590-WTP-GPP-RAQA-QA-1000, Quality Assurance Surveillance, and include WTCC POC regarding S/CI communication.

6.6 EXTERNAL DI NOTIFICATIONS AND REVIEW PROCESS


NOTE:

A current list of S/CI and DI notifications can be found on the WTP project intranet home page. The review process for external notifications is described in sections 6.5 and 6.6.




a. SCREEN DI information regarding defective or recalled items as communicated through DOE Corporate Operating Experience Program documents and external operating experience documents for site-specific relevance, risks, and vulnerabilities.

NOTE:

Safety concerns are discussed with Safety and Health Management to determine if immediate/compensatory action should be initiated.

The applicability review is performed and documented through the project issues management process.

b. IF DI is potentially applicable to WTP, THEN DISTRIBUTE the DI by initiating a Recommendation in accordance with 24590-WTP-GPP-RACA-CR-0110, Condition Report and Recommendation Initiation.

7.0 ACCEPTANCE CRITERIA

N/A

8.0 TRAINING

The following training (e.g., qualifications, training components, certifications) are required in order to perform this procedure:

Role Qualification

Managers, Supervisors, Inspectors (Assigned to Mid-Level)

(CBT) 24590-WTP-CBT-TRA-000546 RR – 24590-WTP-GPP-RAQA-QA-0003

9.0 RECORDS

Records generated during the performance of this procedure include the following:

OIG Notification (CCN)

10.0 REFERENCES

10.1 INTERFACING REFERENCES

24590-WTP-GPP-RAPS-SQ-1044, FIELD MATERIAL RECEIVING

24590-WTP-GPP-RAPS-MM-1103, FIELD MATERIAL WITHDRAWAL AND SHIPPING

24590-WTP-GPP-RAPS-GP-1028, GOVERNMENT PROPERTY – SCRAP/SALVAGE

I ~ =====--+ ............... ........____----i, '-- I




24590-WTP-GPP-RAQS-NC-0002, NONCONFORMANCE REPORTING AND CONTROL

24590-WTP-GPP-RAQS-NC-0001, OPERATING NONCONFORMANCE REPORTING AND CONTROL

24590-WTP-GPP-RAPS-SQ-1041, RECEIVING INSPECTIONS

24590-WTP-GPP-RACA-LL-0001, WTP LESSONS LEARNED

24590-WTP-GPP-RACA-TM-0001, TREND ANALYSIS AND REPORTING

24590-WTP-GPP-RAQA-QA-1000, QUALITY ASSURANCE SURVEILLANCE

24590-WTP-GPP-RACA-CR-0110, CONDITION REPORT AND RECOMMENDATION INITIATION

10.2 DEVELOPMENTAL REFERENCES

24590-WTP-QAM-QA-06-001, QUALITY ASSURANCE MANUAL

24590-WTP-QAM-RAQA-QA-0001, COMMISSIONING AND OPERATIONS QUALITY ASSURANCE MANUAL

DOE G 414.1-3, SUSPECT/COUNTERFEIT ITEMS GUIDE FOR USE WITH 10 CFR 830 SUBPART A, QUALITY ASSURANCE REQUIREMENTS

DOE O 414.1C, QUALITY ASSURANCE

DOE G 414.1-2B, QUALITY ASSURANCE PROGRAM GUIDE

IAEA-TECDOC-1169, MANAGING SUSPECT AND COUNTERFEIT ITEMS IN THE NUCLEAR INDUSTRY

DOE O 414.1D, QUALITY ASSURANCE

10.3 FORM REFERENCES

24590-GCB-F00006, WTP Shipping Request Form 24590-GPA-F00006, Declaration of Excess (DECEX) Form




ATTACHMENT 1 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS

ACRONYMS and ABBREVIATIONS BNI-WTP Bechtel National Inc.- Hanford Tank Waste Treatment and Immobilization Plant DI Defective Item DOE US Department of Energy HSS DOE Office of Health, Safety, and Security NCR Non-Conformance Report OIG Office of Inspector General QA Quality Assurance S/CI Suspect/Counterfeit Item UOS&D Unsatisfactory, Over, Short and/or Damaged WTCC Waste Treatment Completion Company LLC WTP Hanford Tank Waste Treatment and Immobilization Plant

Definitions

suspect/counterfeit item (S/CI)

An item is suspect when inspection or testing indicates that it may not conform to established Government or industry-accepted specifications or national consensus standards or whose documentation, appearance, performance, material, or other characteristics may have been misrepresented by the supplier or manufacturer. A counterfeit item is one that has been copied or substituted without legal right or authority or whose material, performance, or characteristics have been misrepresented by the supplier or manufacturer. Items that do not conform to established requirements are not normally considered S/CIs if nonconformity results from one or more of the following conditions (which must be controlled by site procedures as nonconforming items):

defects resulting from inadequate design or production quality control;

damage during shipping, handling, or storage;

improper installation;

deterioration during service;

degradation during removal;

failure resulting from aging or misapplication; or

other controllable causes.

Subcontract/ Procurement Interface

Individual serving as the Point of Contact responsible for contractual interaction. May also be known as Buyer, Subcontract Administrator, Procurement Representative, etc.




ATTACHMENT 2 S/CI INDICATORS

The following are examples of misrepresented products identified by DOE and US Nuclear Regulatory Commission (NRC) licensees. These are provided as example of S/CI indicators.

1. Visual Inspection (Items may be substandard or fraudulent when):

Name plates, labels, or tags:

Have been altered, photocopied, painted over

Are not secured well

Show incomplete data

Are missing (e.g., preprinted labels normally show typed entries).

Obvious attempts at beautification have been made (e.g., excess painting or wire brushing, evidence of hand painting [touch-up], or stainless steel is painted)

Handmade parts are evident, gaskets are rough cut, or shims and thin metal part edges show evidence of cutting or dressing by hand tools (e.g., filing, hacksaw marking, or use of tin snips or nippers)

Hand-tool marks are on fasteners or other assembly parts (e.g., upset metal exists on screw or bolt heads) or dissimilar parts are evident (e.g., majority of bolts are of the same material and one or more bolts are a different material)

There is a poor fit between assembled items

Configuration is not consistent with other items from the same supplier or varies from that indicated in supplier literature or drawings

There is an unusual box, or unusual packing of component or item

The supplier is not a factory-authorized distributor

Dimensions of the item are inconsistent with the specifications requested on the PO and/or those provided by the supplier at the time of shipment

The item or component matches the description of one that is on a suspect items list

2. Documentation (Documents may be suspect and/or counterfeit when):

Provided from Kobe Steel Ltd, Kobe Steel USA, Kobelco or other implicated affiliates that have admitted to falsification of records. (link to Kobe companies: http://www.kobelco.co.jp/english/about_kobelco/group/ ) or (BNI Procurement Management may be contacted for current list of Kobe affiliates)

The use of correction fluid or correction tape is evident

Type or pitch change is evident

The document is not signed or initialed when required or is excessively faded or unclear (indicating multiple, sequential copying), or data are missing

The name, or title, of the document approver cannot be determined

Technical data is inconsistent (e.g., chemical analysis indicates one material and physical test indicates another)

Certification or test results are identical between items when normal variations should be expected

Document traceability is not clear. The document should be traceable to the item(s)




Technical data are not consistent with code or standard requirements (e.g., no impact test results provided when impact testing is required, or certified material test report physical test data indicates no heat treatment and heat treatment is required)

Documentation is not delivered as required on the PO or is in an unusual format

Lines on forms are bent, broken, or interrupted, indicating data has been deleted or exchanged (e.g., cut and paste)

Handwritten entries of data are on the same document where typed or preprinted data exists

Data on a single line located at different heights indicate the possibility of retyping

3. Fasteners

Head markings are marred, missing, or appear to have been altered

Threads show evidence of dressing or wear (i.e., threads should be of uniform color and finish)

Head markings are inconsistent with a heat lot

Head markings matching one of those identified on the suspect headmark list

4. Electrical Devices

Connections show evidence of previous attachment (e.g., metal upset or marring)

Connections show arcing or discoloration

Fasteners are loose, missing, or show metal upset

Molded case circuit breakers are not consistent with manufacture-provided checklists for detecting substandard and/or fraudulent breakers

Missing, or photocopied, Underwriters Laboratories labels on products requiring such

Altered markings (i.e., hand painted information)

5. Rotating Machinery and Valve Internal Parts

Shows marring, tool impressions, wear marks, traces of Prussian blue or lapping compound, or other evidence of previous attempts at fit-up or assembly

Heat discoloration is evident

Evidence of erosion, corrosion, wire-drawing, or “dimples” (i.e., inverted cone-shaped impressions) on valve discs, seats, or pump impellers)

6. Valves

Painted valve appears to be freshly painted and valve stem has paint on it

Wear marks are on any painted surface

Valve stem is protected, but protection has paint on it

Paint does not match standard original equipment manufacturer (OEM) color

Valve Tags:

Are attached with screws instead of rivets

Are attached in a different location than normal

Appear to be worn or old

Have paint on them




That look newer than the valve

Have no part numbers

Show irregular stamping

Handwheels

Are old looking handwheels on new looking valves

Look sand-blasted or newer than the valve

There are different types of handwheels on valves of the same manufacturer

Bolts and Nuts

Have a used appearance (e.g., excessive wrench marks on flats)

Material is improper (e.g., a bronze nut on a stainless-steel stem)

Valve Body

The ground off casting marks with other markings stamped in the area (i.e., OEM markings are nearly always raised, not stamped)

There are signs of weld repairs

There are incorrect dimensions

There is a freshly sand-blasted appearance, including eye bolts, grease fittings, stem, etc.

There is evidence of previous bolt head scoring on backsides of flanges, or evidence that this area has been ground to remove such marks

On a stainless valve, finish that is unusually shiny indicates bead-blasting. A finish that is unusually dull indicates sand-blasting. The finish on a new valve is in-between.

Manufacturer’s Logo

Is missing

The logo plate looks newer than the valve

The logo plate shows signs of discoloration from previous use

Other

There is foreign material inside the valve (e.g., metal shavings)

There is valve stem packing that shows all the adjustments have been run out

There are in-gate valves, a gate that is off-center when checked through the open end of the valve

There are obvious differences between valves in the same shipment

7. Price

Price is significantly less than that of the competition




ATTACHMENT 3 WTP EMPLOYEE FLOWCHART

Suspect/ Counterfeit Items Process

S/CI

Iden

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Eval

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OIG

WTP Employee Process of Identification of Questionable items that contain characteristics of being S/CI

An item is identified as exhibiting characteristics/indications of

being S/CI

Investigate Item in question, and gather information, photo’s,

etc..

Based on complexity, S/CI Evaluation team may be

formed and receive information to review

Determine applicable Technical Specialists for

Evaluation Team and capture in S/CI Log

Notify S/CI Coordinator, secure item from use and Initiate NCR providing

a description of S/CI concern

Team responds within target of 10 working days regarding the

validity of the S/CI item

Is the Item S/CI?

Fill out OIG Notification form and send to OIG, DOE within 3 days of

decisionConcurrently notify

Occurrence reporting

No

Provide disposition to close NCR, Update S/CI

log and notify S/CI Identifier

Notified of team determination

OIG reviews information and determines if

further involvement on their part is needed

Receive response from OIG, updates

S/CI log, send Notification to

distribution, and provide disposition

for NCR

Receive Notification that OIG is being contacted

Coordinate disposition of the S/CI in accordance

with the applicable procedures referenced in sections 6.2 and 6.4

Based on feedback from OIG, provide

final disposition on NCR

Yes

Validate NCR and ensure tags are

applied

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ATTACHMENT 4 SUBCONTRACTOR/SUPPLIER FLOWCHART

Suspect/ Counterfeit Items Process

S/CI

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Eval

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WTP Supplier/Subcontractor Process of Identifying Questionable items that contain characteristics of being S/CI

An item is identified as exhibiting characteristics/indicators of

being S/CI

The Procurement & Subcontract interface is

informed of the Questionable item and provided information

regarding item

Determine Applicable Technical Specialists for

Evaluation Team and capture in S/CI Log

Based on complexity, S/CI Evaluation team may be

formed and receive information to review

Investigate Item in question and gather

information, photo’s, etc..

Secure item using the Suppliers/Subcontractors

Program, the item is segregated and/or tagged

as Questionable

Team responds within target of 10 working days regarding the

validity of the S/CI item

Is the Item S/CI?

Send notification to OIG, DOE within 3 days of decision

Concurrently notify Occurrence reporting

No

Update S/CI log and notify S/CI Identifier through the Supplier/

Subcontractor interface

Notified of team determination that item

was not S/CI and communicate with

Identifier

OIG reviews information and determines if

further involvement on their part is needed

Receive response from OIG, updates

S/CI log, send Notification to

distribution, and provide disposition

for NCR

Receive Notification that OIG is being contacted

Yes

Update S/CI log and contact Supplier/Subcontract interface to

secure S/CI item from Subcontractor

notify the S/CI Coordinator with

applicable information

Support process of impounding the WTP owned S/CI item from

the Subcontractor/Supplier

Becomes aware of the segregated

Questionable item

Receive Notification that the Questionable item was

determined to be S/CI. And request to impound item

Provide the S/CI item to Buyer

(Subcontractor/Procurement

interface)

S/CI Item received and impounded and

initiate NCR to control item

Notified of team determination that item

was not S/CI

Communicates results to WTP S/CI

Coordinator

Coordinate disposition of the S/CI in accordance with the

applicable procedures referenced in sections 6.3

and 6.4

Based on Feedback from OIG, Provide

Final Disposition on NCR

Validate NCR

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This document has been digitally signed using the Electrosign process.

Document for Signature

Document Number: 2490-WTP-GPP-RAQA-QA-0003 Rev: 5

Participants Signature Completed Status Result Comments

Signers 6/24/2020 6:17 PM

Hart, Dan 6/24/2020 6:23 PM Completed Approve

Fortier, Mike 6/24/2020 6:30 PM Completed Approve

Final Approver 6/24/2020 6:30 PM

Jolly, Raj 6/24/2020 8:24 PM Completed Approve

ELECTR□SIGN

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